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#2179205 - 05/22/18 08:31 PM Community Development dentist or eye doctor
Live 2 Comply Offline
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Could financing for an eye clinic or a dentist office be counted as a community development loan for CRA?

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#2179290 - 05/23/18 02:30 PM Re: Community Development dentist or eye doctor Live 2 Comply
ScoutLaRue Offline
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Do they accept patients with low to moderate income, no insurance, Medicaid, do some sort of payment plan--- and keep records of it?
Is it in or very close to an LMI tract?
Is it a brand new business that will bring new jobs to the community that pay LMI wages? Office staff etc?

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#2179294 - 05/23/18 02:46 PM Re: Community Development dentist or eye doctor Live 2 Comply
Norman Paperman Offline
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Is the area designated as a Health Professional Shortage Area?

https://datawarehouse.hrsa.gov/topics/shortageareas.aspx
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#2179306 - 05/23/18 03:10 PM Re: Community Development dentist or eye doctor Live 2 Comply
RR Jen Offline
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Holy cow, thanks for sharing that link. Searching by addresses (a few clicks away) is cool!
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#2179456 - 05/23/18 07:42 PM Re: Community Development dentist or eye doctor Live 2 Comply
Live 2 Comply Offline
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Thanks for everyone's help! Very beneficial!!

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#2179464 - 05/23/18 08:15 PM Re: Community Development dentist or eye doctor Live 2 Comply
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Norm - I was not aware. Great link. I'm sure Scout's questions, answered affirmatively would add credibility, but how much credit could a lender get if the office located there, but couldn't document LMI needs?
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#2179805 - 05/25/18 02:09 PM Re: Community Development dentist or eye doctor Live 2 Comply
Norman Paperman Offline
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To be honest, I have my first CRA exam coming up using this method. I hate to say that I can't remember the BOLer that shared this with me, but no surprise that I learned of the link from a fellow user.

I think it can hold weight.
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#2179826 - 05/25/18 04:02 PM Re: Community Development dentist or eye doctor Live 2 Comply
CompliantOkie Offline
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:raises hand:
That might have been my link. We got some miles out of that designation. We did not document the specific LMI need for healthcare. We were able to convince our exam team that LMI individuals benefit from any healthcare availability in the community. Granted our exam team is fairly flexible.

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#2179853 - 05/25/18 05:16 PM Re: Community Development dentist or eye doctor CompliantOkie
Princess Romeo Offline

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Originally Posted By CompliantOkie
:raises hand:
That might have been my link. We got some miles out of that designation. We did not document the specific LMI need for healthcare. We were able to convince our exam team that LMI individuals benefit from any healthcare availability in the community. Granted our exam team is fairly flexible.


And THAT is one of the problems with CRA these days. We were denied CD credit for a renewal of a participation loan that had received CD credit in our prior exam - and loan was to a major health care company that purchases hospitals in danger of financial collapse, re-organizes the management of the hospital to keep it open. There were two hospitals in LMI areas in our AA included in the portfolio. Examiners said we couldn't prove a "majority" of benefit to LMI and FURTHER told us that "hospitals are not community services" that qualify for CD.

Yeah - we protested all the way up the chain. Didn't matter.
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